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Waste Minimization/Pollution Agency Inspections & Internal EHS <br /> Prevention Assessments Findings -Waste <br /> s States may require written waste minimization/pollution i Unlabeled or improperly labeled drums—Continues to <br /> prevention plans. be an issue <br /> Generator's Certification on hazardous waste manifest is Container inspections weekly documentations—Missing <br /> certification that facility has waste minimization program weeks,not reading and answering questions carefully <br /> in place. i Improper waste storage(e.g.,containers not closed, <br /> Source reduction measures selected for implementation labels not visible,etc.) <br /> include: Analytical data or profiles to verify a waste is non- <br /> - Employee training in spill prevention,housekeeping, hazardous <br /> operating procedures to reduce waste Land Disposal Restriction forms not completed,or <br /> —Sharing waste minimization practices with tank cleaning completed incorrectly <br /> contractors and inspectors <br /> — Daily walk-throughs to observe for leaks/spills <br /> —Carson and LAHT only:Employee training to observe for <br /> oil-water interface during tank water draws og „p <br /> 109 110 <br /> EHS Document System Waste Training <br /> i Documents in the EHSDS: I What words must appear on the label of every container <br /> of hazardous waste throughout its existence? <br /> —SPCC Plan(and SWPPP, if applicable)in I What is a RCRA Contingency Plan? <br /> Water Section <br /> —Hazardous Waste Section includes guidance What type of waste are spent fluorescent bulbs? <br /> g � If you have not had waste training can you sign a <br /> documents, RCRA contingency plan,waste hazardous waste manifest? <br /> minimization/pollution prevention documents, i What amount of hazardous waste can be accumulated in <br /> tiered permitting documents for wastewater a satellite container? <br /> treatment systems, hazardous waste report <br /> „2 <br /> 111 112 <br /> Remember... Questions <br /> i Wastes should never be taken home <br /> III Wastes should not be transported from the <br /> location where they are generated without <br /> prior approval from EHS A <br /> A <br /> „a „a <br /> 113 114 <br /> 19 <br />